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Section 1: SD (FORM SD)

ora20180531_sd.htm

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

SPECIALIZED DISCLOSURE REPORT

 

 

Ormat Technologies, Inc.

(Exact name of registrant as specified in its charter)

 

Delaware

001-32347

88-0326081

State or other jurisdiction of

incorporation or organization)

(Commission file number)

(IRS Employer Identification No.)

 

 

 

6225 Neil Road, Reno, Nevada 89511-1136
(Address of principal executive offices) (Zip Code)

 

Doron Blachar, CFO

(775) 356-9029

(Name and telephone number, including area code, of the person to contact in connection with this report)

 

 

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.

 

 

 

 

Section 1 – Conflict Minerals Disclosure

 

1.01 – Conflict Minerals Disclosure and Report

 

Conflict Minerals Disclosure

 

This Specialized Disclosure Report on Form SD (this “Form SD”) of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2017 to December 31, 2017 is presented to comply with Rule 13p-1 ("Rule 13p-1") promulgated under the Exchange Act of 1934, as amended (the "Exchange Act"). In accordance with Rule 13p-1 and our Conflict Minerals Policy, published at: http://www.ormat.com/social-responsibility-and-sustainability, we have concluded, in good faith, that during the 2017 calendar year, (i) we have manufactured and contracted to manufacture products (the “Covered Products”) containing conflict minerals and that (ii) the use of these minerals is necessary to the functionality or production of such products. Based on our good faith reasonable country of origin inquiry, the Company has reason to believe that conflict minerals necessary to the functionality of production of the Covered Products may have originated in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”) and that such conflict minerals may not be entirely from recycled or scrap sources.

 

On the basis of these conclusions, the Company proceeded to exercise due diligence with respect to the source and chain of custody of the Conflict Minerals contained in its Covered Products and has submitted its Conflict Minerals Report as an exhibit to this Form SD for the reporting period from January 1, 2017 to December 31, 2017. The Conflict Minerals Report describes the conflict minerals due diligence that the Company has designed and performed. The Conflict Minerals Report has not been subject to an independent private sector audit.

 

Based on the information obtained by the Company during the due diligence process, the Company does not have sufficient information, with respect to the Covered Products, to determine the country of origin of all of the Conflict Minerals in all the Covered Products. However, based on the information that has been obtained, to the extent reasonably determinable by the Company, with respect to the smelters and refineries identified by the Company, the possible countries of origin of the conflict minerals are listed in Annex 2 to the Company’s Conflict Minerals Report, attached to this Form SD as Exhibit 1.01.

 

Copies of this Form SD and the Conflict Minerals Report are also published on a publically available Internet site at http://www.ormat.com/social-responsibility-and-sustainability. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference herein.

 

 

Item 1.02 – Exhibit

 

See Exhibit 1.01 – Conflict Minerals Report.

 

 

 

 

Section 2 – Exhibits

 

Item 2.01 Exhibits

 

 

List below the following exhibit filed as part of this report.

 

 

Exhibit 1.01 – Conflict Minerals Report of Ormat Technologies, Inc.

 

 

Signatures

 

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

 

 

ORMAT TECHNOLOGIES, INC.

By: /s/Doron Blachar

Name: Doron Blachar

Title: CFO

Date: May 31, 2018

 

(Back To Top)

Section 2: EX-1.01 (EXHIBIT 1.01)

ex_115692.htm

 

EX-1.01 (Exhibit 1.01)

 

Conflict Minerals Report of Ormat Technologies, Inc.

For The Year Ended December 31, 2017

 

 

 

Introduction:

 

We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").

 

We are a leading vertically integrated company, currently engaged primarily in the geothermal and recovered energy power business, with the objective of becoming a leading global provider of renewable energy.

 

 

This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2017 to December 31, 2017, which has been prepared in accordance with Rule13p-1 (“Rule 13p-1”), promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 requires every registrant that files reports with the Securities and Exchange Commission ("SEC") under Sections 13(a) or 15 (d) of the Exchange Act to disclose certain information when the registrant manufactures or contracts to manufacture products and the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).

 

As part of Ormat's sustainability approach, our Code of Conduct outlines the Company‘s overall principles and commitment towards legal compliance, ethical conduct, human rights, anti-corruption work and environmental protection. These high expectations extend to Ormat's partners, subcontractors and suppliers. We have adopted a policy (the “Conflict Minerals Policy”) with respect to our sourcing of Conflict Minerals, which is in accordance with the OECD guidance, and implemented a comprehensive conflict minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at http://www.ormat.com/social-responsibility-and-sustainability.

 

Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p-1 and Form SD.

 

 

 

 

1.

Overview

 

Company Overview

 

Ormat and its subsidiaries currently conduct business activities in the following three business segments:

 

 

Electricity Segment: In this segment, we develop, build, own and operate geothermal and recovered energy-based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate.

 

 

Product Segment: In this segment, we design, manufacture and sell equipment for geothermal and recovered energy-based electricity generation and remote power units and provide services relating to the engineering, procurement, construction, operation and maintenance of geothermal, Solar PV and recovered energy-based power plants.

 

 

Other Segment: In this segment, we provide energy storage, demand response and energy management related services, as well as services relating to engineering, procurement, construction, operation and maintenance of energy storage units through our Viridity business.

 

Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.

 

For more information about Ormat, please visit www.ormat.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.

 

Supply Chain

 

In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of the Conflict Minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment or the Other Segment because neither of these segments involves the sale of products by the Company.

 

In connection to our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and are necessary to the functionality and production of our products with regards to the following raw materials or components: steel (low and high grade), electronic cards and electronic cables (including tin plating). All such raw materials are purchased from various suppliers. We also use subcontractors to manufacture some of our products' components and for construction activities of power plants. We work with a large number of suppliers throughout the world and often there are multiple tiers between the gold, tin, tantalum and tungsten (3TG) mines and our direct suppliers. Therefore, we have to rely on our Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors to provide us with accurate information on the origin of the 3TG in the components we purchase from them that are included in our products. In order to overcome the difficulties of receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy and activities to its suppliers, and has adopted the Responsible Minerals Initiative's ("RMI") (formerly the CFSI) reporting template for surveying suppliers.

 

 

 

 

2.

Reasonable Country of Origin Inquiry (RCOI)

 

Ormat has conducted in good faith a reasonable country of origin inquiry (“RCOI”) to determine whether any of the Conflict Minerals originated in the Covered Countries or are from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conducted due diligence on the source and chain of custody of those Conflict Minerals with a large number of suppliers we identified as those from whom we source materials or components that may contain 3TG.

 

 

As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated in the Covered Countries, including the following:

 

 

Internal assessment and analysis of our products to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of these products.

 

 

Compiled a list of suppliers based on the applicable suppliers list that Ormat purchased from during the calendar year 2017, which was issued using the Ormat Management System (OMS) by IT developers and according to the criteria defined by the OMS manager and the purchasing manager. The list includes a total of 1,362 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in the "Purchase Types" field were applicable for the RCOI under Rule 13p-1.

 

 

In order to identify and assess risks in the supply chain, we undertook a risk-based approach and engaged the suppliers representing approximately 90% of our 2017 expenditures on procurement for the Product Segment. On that basis, Ormat's final Tier 1 suppliers list ("relevant suppliers") includes a total of 125 suppliers.

 

 

Contracted a third party service provider to assist us with the survey of suppliers. Through this third party service provider, we sent letters to our relevant suppliers to explain Rule 13p-1 and to refer the suppliers to online training materials and instructions. We solicited information from our relevant suppliers of raw materials and components of products using the standard template of the Responsible Business Alliance (formerly, the Electronic Industry Citizenship Coalition) (the “RBA”) known as the Conflict Minerals Reporting Template ("CMRT"). The RBA oversees the RMI. The CMRT is designed to facilitate the transfer of information through the supply chain regarding each mineral’s country of origin and the smelters and refiners being utilized for the mineral. The CMRT requires suppliers to make representations regarding: (i) the country of origin for the Conflict Minerals contained in the components or products it provides to the Company; (ii) all of the smelters in the supplier’s supply chain for such Conflict Minerals; (iii) whether such smelters have been validated as being in compliance with the RMI’s Responsible Minerals Assurance Process (formerly the Conflict-Free Smelter Program) (the “RMAP”); (iv) whether the supplier has its own conflict minerals policy that requires its own direct suppliers to be “DRC conflict-free”; and (v) whether the supplier uses CMRT with its own suppliers to gather similar information. Communications from the Company to its suppliers and responses received from the suppliers are stored electronically by the Company together with copies of internal communications that relate to the Company’s due diligence.

 

 

Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses, and sent reminders to suppliers who did not respond to our requests for information or whose responses required further clarification. Compared smelters or refiners that were identified by our suppliers against the list of facilities that have been validated by RMAP as well as documented country of origin information. The complete list of identified suppliers is included as Annex 1 hereto and the complete list of counties of origin is included in Annex 2 hereto.

 

 

 

 

Currently, we do not have sufficient information from our suppliers to determine the complete list of countries of origin of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries and are not from recycled or scrap sources.

 

Based on these results, Ormat conducted due diligence activities and described these activities in this Report.

 

3.

Due Diligence Framework

 

We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing and the related supplements for gold, tin, tantalum and tungsten.

 

4.

Due Diligence Measures

 

Our due diligence efforts for the reporting period from January 1, 2017 to December 31, 2017 included the following steps:

 

4.1

Establish strong Company management systems for conflict minerals supply chain due diligence and reporting compliance

 

The Company implemented the following measures:

 

 

Established a cross- functional conflict minerals steering committee comprised of representatives from procurement and finance departments to direct the overall efforts of the conflict minerals compliance program, with VP finance and accounting as the process owner.

 

 

 

 

 

Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and its adjoining countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach regarding illegal trade of natural resources and promotes the procurement of minerals from credible and conflict-free sources. Pursuant to our Conflict Minerals Policy, we strive to ensure that purchased metals originate only from smelters validated as being conflict-free; however the Company does not seek to eliminate sourcing from the Covered Countries. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policies outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The Company's Conflict Minerals Policy is available at: http://www.ormat.com/social-responsibility-and-sustainability.

 

 

Maintain a grievance mechanism, in which concerns and violations of the Conflict Minerals Policy can be reported to Ormat:

 

 

online via our website www.ormat.com; or

 

 

by electronic mail to the following address: ormat@ormat.com.

 

 

Strengthened its engagement with suppliers by referring suppliers to training materials that includes an overview of the applicable SEC rules and instructions on how to respond to the survey.

 

 

Incorporated a conflict minerals clause in its master purchasing agreements for all new contracts, requiring our suppliers to cooperate with us and provide us the information required to perform our analysis of conflict minerals.

 

 

Implemented a requirement to maintain records relating to conflict minerals due diligence and responsible mineral sourcing for a minimum of five years.

 

4.2

Identify and assess risks in the supply chain

 

To identify risks in our supply chain, we undertook the following measures:

 

We identified two risks in the supply chain: (i) the risk of not receiving timely and accurate information from the supplier; and (ii) the risk of not being able to replace a supplier, while trying to move towards the goal of being a conflict-free company. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers’ characteristics, including the extent to which the Company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to focus our risk mitigation efforts according to the supplier level of risk.

 

As part of the risk assessment phase, Ormat decided to focus on the top approximately 90% of the purchasing spend in 2017. We have identified that out of the responses received, 35% of Ormat's relevant suppliers have a policy in place that addresses conflict minerals sourcing.

 

Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were marked for follow up.

 

 

 

 

We identified the smelters and refiners in the supply chain by conducting a supply chain survey using the CMRT, requesting suppliers to identify smelters and refiners and country of origin of the Conflict Minerals in products supplied to Ormat. In addition, we compared smelters and refiners identified by the supply chain survey against the list of facilities that received RMAP’s “conformant” and “active” designations. The RMAP is a program in which the RMI works with independent third-party auditors or cross-certification programs to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners that agree to undergo an audit or to take part in a cross-certification program.

 

 

A smelter or refiner receives an RMAP “conformant” designation from the RMI if the smelter or refiner (i) completes an independent third-party audit, (ii) adheres to the RMAP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals, (iii) has been found by its independent third-party auditor to possess the systems and processes to support responsible sourcing of Conflict Minerals and can provide evidence to support its sourcing activities and (iv) maintains good standing in the program, through a continual validation process. The RMI’s RMAP “conformant” list (formerly, the CFSI’s CFSP “compliant” list) provides the names, locations and links to conflict minerals policies of all smelters and refiners deemed compliant with the RMAP’s assessment protocols.  Smelters and refiners with a “re-audit in progress” are still considered to be RMAP “conformant.”

 

 

Smelters and refiners labeled as RMAP “active” by the RMI (formerly, CFSP “active,” as determined by the CFSI) have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. They may not retain their “active” status if, among other things, they are unresponsive to requests for re-audit or corrective action past a certain time.

 

 

Companies that have been determined to be downstream of smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process.

 

 

4.3

Design and implement a strategy to respond to identified risks

 

To address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes the following:

 

Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, and legal compliance and measures for implementation. We also ask suppliers to work with sub-tier suppliers to ensure traceability of these materials at least to the smelter level, e.g. by using the CMRT.

 

 

 

 

Ormat's senior management, including the CEO, CFO, EVP Electricity, EVP Products, EVP Business Development and Marketing, EVP Projects, EVP Engineering and EVP Operations, was updated with the risk analysis and risk management actions and outcomes.

 

Suppliers who provided incomplete or inconsistent responses were sent a corrective action letter for follow up, requesting clarification.

 

Suppliers that did not respond to our initial survey request were sent follow-up letters requesting that they provide the necessary information.

 

Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.

 

4.4   Carry out independent third-party audit of smelter/refiner’s due diligence practices

 

We do not typically have direct relationships with 3TG smelters and refiners and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on cross- industry initiatives, such as those led by the RMI, to conduct smelter and refiner due diligence.

 

4.5 Report on supply chain due diligence

 

Our Conflict Minerals Policy states that we will comply with Section 1502 of the Dodd Frank Act that includes filing a Form SD and this Report with the SEC and publishing it so that it may be publicly available on the Internet. The Company's Conflict Minerals Reports can also be viewed at: http://www.ormat.com/social-responsibility-and-sustainability.

 

 

5

The Company’s Due Diligence Findings and Conclusions

 

We conducted a supply-chain survey of the 125 relevant suppliers that we identified as potentially contributing necessary Conflict Minerals to our products. The overall response rate to this survey was approximately 46%. The responses included the names and locations of smelters and refiners (see Annex 1) and possible countries of origin (see Annex 2) that process Conflict Minerals.

 

Our supply chain is complex and there are multiple tiers between the Company and the mine. Accordingly, we rely on our suppliers to provide information on the origin of the 3TG contained in components that are supplied to us to be included in our products.

 

Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were unable to accurately report which specific smelters were part of the supply chain of the components that were sold to Ormat in 2017.

 

 

 

 

In light of this lack of conclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG or their countries of origin. In addition, the information gathered from our suppliers is not gathered on a continuous real-time basis.

 

Smelters or refiners verified as RMAP Conformant or Active:

 

Tantalum

40 of 43 (93%)

 

Tin

73 of 83 (88%)

 

Tungsten

42 of 46 (91%)

 

Gold

108 of 150 (72%) 

 

Total

263 of 322 (82%)

 

 

 

Status of identified smelters or refiners:

 

 

2017

 

“RMAP Conformant”1

254

 

“RMAP Active”2

9

 

“Not RMAP Conformant or Active”3

59

 

Total

322

 

 

6. Steps to be taken to mitigate risk

The Company has taken, and intends to continue to take, steps to improve its due diligence processes. Due diligence is an ongoing, proactive and reactive process, and the Company is continually working to improve the process to identify Conflict Minerals in its Covered Products. The Company plans to continue to inform suppliers about their role in the Company’s conflict minerals compliance program and to engage with its suppliers to obtain current, accurate and complete information about the supply chain. The Company intends to monitor the performance and efficiency of its due diligence efforts to ensure responsible sourcing in compliance with its Conflict Minerals Policy and increase transparency in its supply chain.

 

 


1  “RMAP Conformant” means that the smelter or refiner was listed as conformant with the RMI’s Responsible Minerals Assurance Process (RMAP) assessment protocols, including through mutual recognition and those indicated as “re-audit in process.” Included smelters or refiners were not necessarily Conformant for all or part of 2017 and may not continue to be Conformant for any future period.

2  “RMAP Active” means that the smelter or refiner is a participant in the RMAP and has committed to undergo an audit or is participating in a cross-recognized certification program.

3  “Not RMAP Conformant or Active” means the smelter or refiner is not listed as “Conformant” or “Active.”

 

 

 

 

Specific steps the Company has taken and continues to take to manage risks include:

 

 

Continue working with our global supply chain to obtain current, accurate and complete information about the supply chain and ensure responsible sourcing and assure compliance with international regulations. Continue to strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys.

 

 

Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy.

 

 

Caution Concerning Forward- Looking Statements

 

Information provided in this Report may contain statements relating to current expectations and plans that are "forward- looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forward- looking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. For a discussion of such risks and uncertainties, see "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on March 16, 2018 and its other filings. These forward- looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.

 

 

 

 

Annex 1- Smelter or Refiner Names in Supply Chain

 

Metal

Smelter Name

Smelter Country

RMAP Smelter Status

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

Active

Gold

Remondis Argentia B.V.

NETHERLANDS

Active

Gold

L'Orfebre S.A.

ANDORRA

Active

Gold

Modeltech Sdn Bhd

MALAYSIA

Active

Gold

Bangalore Refinery

INDIA

Active

Gold

NH Recytech Company

KOREA, REPUBLIC OF

Active

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

Active

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

Conformant

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

Conformant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

Conformant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

Conformant

Gold

Argor-Heraeus S.A.

SWITZERLAND

Conformant

Gold

Asahi Pretec Corp.

JAPAN

Conformant

Gold

Asaka Riken Co., Ltd.

JAPAN

Conformant

Gold

Aurubis AG

GERMANY

Conformant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

Conformant

Gold

Boliden AB

SWEDEN

Conformant

Gold

C. Hafner GmbH + Co. KG

GERMANY

Conformant

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

Conformant

Gold

Cendres + Metaux S.A.

SWITZERLAND

Conformant

Gold

Chimet S.p.A.

ITALY

Conformant

Gold

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

Conformant

Gold

DODUCO Contacts and Refining GmbH

GERMANY

Conformant

Gold

Dowa

JAPAN

Conformant

Gold

Eco-System Recycling Co., Ltd.

JAPAN

Conformant

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

Conformant

 

 

 

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Gold

HeeSung Metal Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

Heimerle + Meule GmbH

GERMANY

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

Conformant

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

Conformant

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

Conformant

Gold

Istanbul Gold Refinery

TURKEY

Conformant

Gold

Japan Mint

JAPAN

Conformant

Gold

Jiangxi Copper Co., Ltd.

CHINA

Conformant

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

Conformant

Gold

Asahi Refining Canada Ltd.

CANADA

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

Conformant

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

Conformant

Gold

Kazzinc

KAZAKHSTAN

Conformant

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

Conformant

Gold

Kojima Chemicals Co., Ltd.

JAPAN

Conformant

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

Conformant

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

Conformant

Gold

Materion

UNITED STATES OF AMERICA

Conformant

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

Conformant

Gold

Metalor Technologies S.A.

SWITZERLAND

Conformant

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

Conformant

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

Conformant

Gold

Mitsubishi Materials Corporation

JAPAN

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Conformant

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

Conformant

Gold

Nihon Material Co., Ltd.

JAPAN

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

Conformant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant"

(OJSC Krastsvetmet)

RUSSIAN FEDERATION

Conformant

Gold

PAMP S.A.

SWITZERLAND

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

Conformant

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

Conformant

Gold

PX Precinox S.A.

SWITZERLAND

Conformant

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Conformant

Gold

Royal Canadian Mint

CANADA

Conformant

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

Conformant

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

Conformant

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

Conformant

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

Conformant

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

Conformant

Gold

Tokuriki Honten Co., Ltd.

JAPAN

Conformant

Gold

Torecom

KOREA, REPUBLIC OF

Conformant

Gold

Umicore Brasil Ltda.

BRAZIL

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

Conformant

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Gold

Valcambi S.A.

SWITZERLAND

Conformant

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

Conformant

Gold

Yamakin Co., Ltd.

JAPAN

Conformant

Gold

Yokohama Metal Co., Ltd.

JAPAN

Conformant

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

Conformant

Gold

SAFINA A.S.

CZECH REPUBLIC

Conformant

Gold

Umicore Precious Metals Thailand

THAILAND

Conformant

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

Conformant

Gold

Republic Metals Corporation

UNITED STATES OF AMERICA

Conformant

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Conformant

Gold

Al Etihad Gold LLC

UNITED ARAB EMIRATES

Conformant

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

Conformant

Gold

T.C.A S.p.A

ITALY

Conformant

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

Marsam Metals

BRAZIL

Conformant

Gold

SAAMP

FRANCE

Conformant

Gold

Italpreziosi

ITALY

Conformant

Gold

SAXONIA Edelmetalle GmbH

GERMANY

Conformant

Gold

WIELAND Edelmetalle GmbH

GERMANY

Conformant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

Conformant

Gold

AU Traders and Refiners

SOUTH AFRICA

Conformant

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Gold

Planta Recuperadora de Metales SpA

CHILE

Conformant

Gold

Safimet S.p.A

ITALY

Conformant

Tantalum

Asaka Riken Co., Ltd.

JAPAN

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

Conformant

Tantalum

Exotech Inc.

UNITED STATES OF AMERICA

Conformant

Tantalum

F&X Electro-Materials Ltd.

CHINA

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

Conformant

Tantalum

Jiujiang Nonferrous Metals Smelting Company Limited

CHINA

Conformant

Tantalum

LSM Brasil S.A.

BRAZIL

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

Conformant

Tantalum

Mineracao Taboca S.A.

BRAZIL

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Conformant

Tantalum

NPM Silmet AS

ESTONIA

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

Conformant

Tantalum

QuantumClean

UNITED STATES OF AMERICA

Conformant

Tantalum

RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng

Tantalum & Niobium Co., Ltd.

CHINA

Conformant

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

Conformant

Tantalum

Taki Chemical Co., Ltd.

JAPAN

Conformant

Tantalum

Telex Metals

UNITED STATES OF AMERICA

Conformant

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

Conformant

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

Conformant

Tantalum

FIR Metals & Resource Ltd.

CHINA

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

Conformant

Tantalum

KEMET Blue Metals

MEXICO

Conformant

Tantalum

H.C. Starck Co., Ltd.

THAILAND

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

Conformant

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

Conformant

Tantalum

H.C. Starck Ltd.

JAPAN

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

Conformant

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

Conformant

Tantalum

Global Advanced Metals Aizu

JAPAN

Conformant

Tantalum

KEMET Blue Powder

UNITED STATES OF AMERICA

Conformant

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

Conformant

Tantalum

Power Resources Ltd.

MACEDONIA, THE FORMER YUGOSLAV

REPUBLIC OF

Conformant

Tantalum

Jiujiang Janny New Material Co., Ltd.

CHINA

Conformant

Tin

Modeltech Sdn Bhd

MALAYSIA

Active

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

Conformant

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

CHINA

Conformant

Tin

Alpha

UNITED STATES OF AMERICA

Conformant

Tin

CV Gita Pesona

INDONESIA

Conformant

Tin

PT Aries Kencana Sejahtera

INDONESIA

Conformant

Tin

CV Serumpun Sebalai

INDONESIA

Conformant

Tin

CV United Smelting

INDONESIA

Conformant

Tin

Dowa

JAPAN

Conformant

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

Conformant

Tin

Fenix Metals

POLAND

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

Conformant

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

Conformant

Tin

China Tin Group Co., Ltd.

CHINA

Conformant

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

Conformant

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

Conformant

Tin

Mineracao Taboca S.A.

BRAZIL

Conformant

Tin

Minsur

PERU

Conformant

Tin

Mitsubishi Materials Corporation

JAPAN

Conformant

Tin

Nankang Nanshan Tin Manufactory Co., Ltd.

CHINA

Conformant

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

Conformant

Tin

Operaciones Metalurgical S.A.

BOLIVIA (PLURINATIONAL STATE OF)

Conformant

Tin

PT Artha Cipta Langgeng

INDONESIA

Conformant

Tin

PT Babel Inti Perkasa

INDONESIA

Conformant

Tin

PT Bangka Tin Industry

INDONESIA

Conformant

Tin

PT Belitung Industri Sejahtera

INDONESIA

Conformant

Tin

PT Bukit Timah

INDONESIA

Conformant

Tin

PT DS Jaya Abadi

INDONESIA

Conformant

Tin

PT Eunindo Usaha Mandiri

INDONESIA

Conformant

Tin

PT Karimun Mining

INDONESIA

Conformant

Tin

PT Mitra Stania Prima

INDONESIA

Conformant

Tin

PT Panca Mega Persada

INDONESIA

Conformant

Tin

PT Prima Timah Utama

INDONESIA

Conformant

Tin

PT Refined Bangka Tin

INDONESIA

Conformant

Tin

PT Sariwiguna Binasentosa

INDONESIA

Conformant

Tin

PT Stanindo Inti Perkasa

INDONESIA

Conformant

Tin

PT Sumber Jaya Indah

INDONESIA

Conformant

Tin

PT Timah (Persero) Tbk Kundur

INDONESIA

Conformant

Tin

PT Timah (Persero) Tbk Mentok

INDONESIA

Conformant

Tin

PT Tinindo Inter Nusa

INDONESIA

Conformant

Tin

PT Tommy Utama

INDONESIA

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

Conformant

Tin

Soft Metais Ltda.

BRAZIL

Conformant

Tin

Thaisarco

THAILAND

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

Conformant

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

Conformant

Tin

Yunnan Tin Company Limited

CHINA

Conformant

Tin

CV Venus Inti Perkasa

INDONESIA

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

Conformant

Tin

Melt Metais e Ligas S.A.

BRAZIL

Conformant

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

Conformant

Tin

PT Inti Stania Prima

INDONESIA

Conformant

Tin

CV Ayi Jaya

INDONESIA

Conformant

Tin

CV Dua Sekawan

INDONESIA

Conformant

Tin

CV Tiga Sekawan

INDONESIA

Conformant

Tin

Resind Industria e Comercio Ltda.

BRAZIL

Conformant

Tin

Metallo Belgium N.V.

BELGIUM

Conformant

Tin

Metallo Spain S.L.U.

SPAIN

Conformant

Tin

PT Bangka Prima Tin

INDONESIA

Conformant

Tin

PT Sukses Inti Makmur

INDONESIA

Conformant

Tin

PT Kijang Jaya Mandiri

INDONESIA

Conformant

Tin

PT Menara Cipta Mulia

INDONESIA

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

Conformant

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

Conformant

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

Conformant

Tin

Gejiu Jinye Mineral Company

CHINA

Conformant

Tin

PT Lautan Harmonis Sejahtera

INDONESIA

Conformant

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tin

PT Bangka Serumpun

INDONESIA

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

Active

Tungsten

A.L.M.T. TUNGSTEN Corp.

JAPAN

Conformant

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

Conformant

Tungsten

Japan New Metals Co., Ltd.

JAPAN

Conformant

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Conformant

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

Conformant

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

Conformant

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

VIET NAM

Conformant

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

Conformant

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

Conformant

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Conformant

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

Conformant

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Conformant

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co. KG

GERMANY

Conformant

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

Conformant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

Conformant

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

Conformant

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

Conformant

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

Conformant

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CHINA

Conformant

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

Conformant

Tungsten

ACL Metais Eireli

BRAZIL

Conformant

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

Conformant

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

Conformant

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

Not Conformant or Active

Gold

Caridad

MEXICO

Not Conformant or Active

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

Not Conformant or Active

Gold

Chugai Mining

JAPAN

Not Conformant or Active

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Not Conformant or Active

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

Not Conformant or Active

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

Not Conformant or Active

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

Not Conformant or Active

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

Not Conformant or Active

Gold

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

Not Conformant or Active

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

Not Conformant or Active

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

Not Conformant or Active

Gold

Lingbao Gold Co., Ltd.

CHINA

Not Conformant or Active

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

Not Conformant or Active

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

Not Conformant or Active

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

Not Conformant or Active

Gold

Elemetal Refining, LLC

UNITED STATES OF AMERICA

Not Conformant or Active

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

Not Conformant or Active

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

Not Conformant or Active

Gold

Samwon Metals Corp.

KOREA, REPUBLIC OF

Not Conformant or Active

Gold

Schone Edelmetaal B.V.

NETHERLANDS

Not Conformant or Active

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

Not Conformant or Active

Gold

So Accurate Group, Inc.

UNITED STATES OF AMERICA

Not Conformant or Active

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

Not Conformant or Active

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

Not Conformant or Active

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Gold

Morris and Watson

NEW ZEALAND

Not Conformant or Active

Gold

Guangdong Jinding Gold Limited

CHINA

Not Conformant or Active

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

Not Conformant or Active

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

Not Conformant or Active

Gold

Sudan Gold Refinery

SUDAN

Not Conformant or Active

Gold

Tony Goetz NV

BELGIUM

Not Conformant or Active

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

Not Conformant or Active

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

Not Conformant or Active

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

Not Conformant or Active

Gold

Sai Refinery

INDIA

Not Conformant or Active

Gold

Universal Precious Metals Refining Zambia

ZAMBIA

Not Conformant or Active

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

Not Conformant or Active

Gold

Morris and Watson Gold Coast

AUSTRALIA

Not Conformant or Active

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

Not Conformant or Active

Gold

Pease & Curren

UNITED STATES OF AMERICA

Not Conformant or Active

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

Not Conformant or Active

Gold

African Gold Refinery

UGANDA

Not Conformant or Active

Tantalum

Duoluoshan

CHINA

Not Conformant or Active

Tantalum

King-Tan Tantalum Industry Ltd.

CHINA

Not Conformant or Active

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd.

CHINA

Not Conformant or Active

Tin

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

Not Conformant or Active

Tin

Estanho de Rondonia S.A.

BRAZIL

Not Conformant or Active

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

Not Conformant or Active

Tin

Electro-Mechanical Facility of the Cao Bang

Minerals & Metallurgy Joint Stock Company

VIET NAM

Not Conformant or Active

 

 

 

 

Metal Smelter Name Smelter Country RMAP Smelter Status

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

Not Conformant or Active

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

Not Conformant or Active

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

Not Conformant or Active

Tin

Super Ligas

BRAZIL

Not Conformant or Active

Tin

PT O.M. Indonesia

INDONESIA

Not Conformant or Active

Tin

Pongpipat Company Limited

MYANMAR

Not Conformant or Active

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

Not Conformant or Active

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CHINA

Not Conformant or Active

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CHINA

Not Conformant or Active

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

Not Conformant or Active

 

 

Annex 2- Country of Origin (COO) Inquiry Results*

 

GOLD

TANTALUM

TIN

TUNGSTEN

ANDORRA

BRAZIL

BELGIUM

AUSTRIA

AUSTRALIA

CHINA

BOLIVIA (PLURINATIONAL STATE OF)

BRAZIL

AUSTRIA

ESTONIA

BRAZIL

CHINA

BELGIUM

GERMANY

CHINA

GERMANY

BRAZIL

INDIA

INDONESIA

JAPAN

CANADA

JAPAN

JAPAN

KOREA, REPUBLIC OF

CHILE

KAZAKHSTAN

MALAYSIA

PHILIPPINES

CHINA

MACEDONIA, THE FORMER YUGOSLAV

REPUBLIC OF

MYANMAR

RUSSIAN FEDERATION

CZECH REPUBLIC

MEXICO

PERU

UNITED STATES OF AMERICA

 

 

 

 

GOLD TANTALUM TIN TUNGSTEN

FRANCE

RUSSIAN FEDERATION

PHILIPPINES

VIET NAM

GERMANY

THAILAND

POLAND

 

INDIA

UNITED STATES OF AMERICA

SPAIN

 

INDONESIA

 

TAIWAN, PROVINCE OF CHINA

 

ITALY

 

THAILAND

 

JAPAN

 

UNITED STATES OF AMERICA

 

KAZAKHSTAN

 

VIET NAM

 

KOREA, REPUBLIC OF

 

 

 

KYRGYZSTAN

 

 

 

LITHUANIA

 

 

 

MALAYSIA

 

 

 

MEXICO

 

 

 

NETHERLANDS

 

 

 

NEW ZEALAND

 

 

 

PHILIPPINES

 

 

 

POLAND

 

 

 

RUSSIAN FEDERATION

 

 

 

SAUDI ARABIA

 

 

 

SINGAPORE

 

 

 

SOUTH AFRICA

 

 

 

SPAIN

 

 

 

SUDAN

 

 

 

SWEDEN

 

 

 

SWITZERLAND

 

 

 

TAIWAN, PROVINCE OF CHINA

 

 

 

THAILAND

 

 

 

TURKEY

 

 

 

UGANDA

 

 

 

UNITED ARAB EMIRATES

 

 

 

UNITED STATES OF AMERICA

 

 

 

UZBEKISTAN

 

 

 

ZAMBIA

 

 

 

ZIMBABWE

 

 

 

 

 

 

 

* As SORs did not provide information on Location of Mine in their CMRTs, and the Company was not able to establish from the SORs sourcing information on their 3TG, we have listed in the COO the closest indication provided as to the source of Conflict Minerals, i.e. the Smelter Country as reported in the suppliers' CMRT.

 

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